DFI Transparency

Tool

November 2021
DFI TRANSPARENCY TOOL
Publish What You Fund has developed the DFI Transparency Tool to improve the
systematic and timely disclosure of relevant information by development finance
institutions (DFIs). The tool is designed to meet two functions:

• Provide detailed, granular guidance to DFIs on the information they should disclose.

• Provide the framework for analysis by which Publish What You Fund will measure
DFI transparency in an initial public pilot index in late 2022.

This DFI Transparency Tool is the culmination of two years of in depth and collaborative
research assessing the disclosure practices of the world’s leading multilateral and
bilateral DFIs. Further details of our research findings and the rationale for the tool can
be found in our Advancing DFI Transparency report.

DFIs can improve their transparency by providing comparable, timely, and relevant
information for use by a range of stakeholders in line with the specific information
fields included in the tool.
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3
 INDICATOR SURVEY QUESTION DEFINITION ADDITIONAL
DEFINITIONS AND NOTES

CORE INFORMATION

ORGANISATIONAL LEVEL INDICATORS

Does the development finance Publish What You Fund completes an assessment of the The following characteristics are
institution (DFI) have a disclosure or quality of disclosure policies based on the overarching assessed for disclosure / access to
access to information policy? approach taken in the Global Right to Information (RTI) Rating. information policies:

For bilateral DFIs does the disclosure/ FOIA: The definition used in the Global RTI Rating is that it Presumption of disclosure: to score
access to information policy include has to be a law in the strict sense. It must include the right for this indicator, a disclosure policy
reference to a Freedom of Information of access to information, this right has to be enforceable must have a specific clause that states
Act (FOIA)? and there must be compliant, court and high court appeal disclosure as the rule, thereby requiring
possibilities. Decrees are included if they meet the same a compelling reason for non-disclosure.
standards. In addition, the FOIA must be in use for at least the
executive part of the government; therefore, FOIAs which are Limitations on commercially sensitive
only adopted, approved or still in draft form are not counted. information and sensitive internal
deliberations information: to score on
this indicator, non-disclosure clauses
related to these matters must (a)
clearly define a legitimate interest that
1. Disclosure / access to is being protected, (b) be limited to
information policy protecting that interest against harm,
and (c) be subject to a public interest
override. To score on this indicator all
three sub-criteria must be met.

Independent appeals process: to

score for this indicator, information
requesters must have a right to
lodge an appeal regarding the
application of the disclosure policy
with an independent appeals body
which includes individuals that are
independent from the organisation
and which has the power to make
decisions on how the policy has been
applied in any particular case.

Does the DFI disclose its data in an The overall accessibility of data through the organisation’s
accessible manner? portals, project databases or searchable data sources. These
2. Accessibility are scored using three criteria: 1) the portal allows free, bulk
export of data, 2) it contains detailed disaggregated data,
3) the data is published under an open licence.

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 INDICATOR SURVEY QUESTION DEFINITION ADDITIONAL
DEFINITIONS AND NOTES

Does the DFI disclose an annual report? Annual reports outline basic (normally aggregate) To score for this indicator, the annual
information about how money was spent in the previous report needs to include details of
year, broken down by sector and/or country. This should be where the organisation is spending its
backward looking. resources and the information needs to
3. Annual reports cover current activity period.
Annual reports that are up-to-date within their regular cycle,
i.e. the organisation publishes an annual report a year behind, Integrated reports that combine
the most recent document within this time frame is accepted. annual reporting and financial
reporting are accepted for this field.

PROJECT LEVEL INDICATORS

Does the DFI disclose a project title? The project title is its name. This is preferably the formal name For non-sovereign projects the project
of the activity, but does not have to be. In the case of non- title may be given as the client’s name.
Does the DFI disclose a unique sovereign activities, the title may be given as the name of the
identifier for the project? investee company as long as it satisfies other requirements. The project ID must be stated clearly
on the page. It is not sufficient if it
The title needs to be complete with any activity specific is only stated in the URL. It must be
4. Project identification abbreviations or acronyms explained. General commercial numeric or alpha-numeric.
abbreviations such as ltd. or s.a. are acceptable.

The unique identifier is a unique reference ID for the activity,

e.g. a project number. It allows an activity to be referred to
and searched for by a code, which can be used to retrieve the
project from a database or filing system.

Does the DFI disclose the current This shows the current status of the activity, e.g. whether the
status of the activity? activity is currently under design, being implemented, has
finished or has been cancelled.
5. Status
For non-sovereign projects the status may be pending
approval, active, completed, or similar.

Does the DFI disclose a description of The description of the activity is a meaningful descriptive text, The description of the activity needs to
the activity? longer than the title, explaining what the activity is. contain a minimum of 80 characters
in order to be considered a description
Does the DFI disclose a project/activity A project rationale is the reason an activity is taking place. rather than just a title.
6. Project description objective/rationale? The rationale could be a narrative or a theory of change.
The information can be contained in
Does the DFI disclose the expected The expected outcomes are the development objectives that more than one web page, data field
outcomes of an activity? the activity intends to achieve. The expected outcomes may and/or document.
be reported as a narrative.

5
 INDICATOR SURVEY QUESTION DEFINITION ADDITIONAL
DEFINITIONS AND NOTES

Does the DFI disclose the region the Region: the region (e.g. sub-Saharan Africa) where an activity For sub-national location, capital city
activity takes place in? takes place. of country/countries of activity will be
accepted in instances where it is not
Does the DFI disclose the country the Country: the country or countries where an activity takes place. possible to be more specific.
7. Location activity takes place in?
Sub-national location: information about where the activity is
Does the DFI disclose the sub-national located within a country. This may be a province or city, or it could
location the activity takes place in? be geo-coded (whereby the precise longitude and latitude is
published). It needs to be stated separately and explicitly.

8. Domicile Does the DFI disclose the domicile of The investee company’s (the recipient of funds) place of
(non-sovereign only) the investee? incorporation.

Does the DFI disclose the activity as Sovereign projects are projects that have been financed with For institutions that exclusively do
sovereign or non-sovereign? the guarantee of a sovereign entity (a national or sub-national either sovereign or non-sovereign work,
government). a statement to this effect is sufficient in
Or place project-level disclosure.
9. Sovereign / non-sovereign Non-sovereign projects are projects that have been financed
Does the DFI disclose the activity as without the guarantee of a sovereign entity (a national or
public sector or private sector? sub-national government, or in some cases a municipality).
Broadly, sovereign means public sector financing while non-
sovereign therefore means private sector financing.

Does the DFI disclose the sector of the The sectors of the activity explain whether this is, for example, If projects are presented by sector on an
activity? a health or education project. It does not count if it is just organisation’s website, it must be clearly
10. Sector mentioned incidentally within the title or description. It needs stated whether the organisation works
Does the DFI disclose the sub-sector of to be stated separately and explicitly. only in those sectors that are listed.
the activity?

Does the DFI disclose the investment This shows the investment instrument of an activity, e.g. loan,
11. Investment instrument instrument of an activity? equity investment, guarantee or other investment product.
This needs to be explicitly stated per activity.

Does the DFI disclose the total The total cost of an investment at the time of signing, including These should be disclosed in a
investment cost? financing from co-investors and from the project client. consistent reporting currency.

Does the DFI disclose the DFI DFI commitment refers to the financial commitment made The disbursement figure may vary
commitment for the investment? by the DFI for the activity as a whole, for the lifetime of the from the committed amount due to
12. Project costs activity. This is generally a high-level commitment rather than changing conditions after the point of
Does the DFI disclose the a detailed breakdown of the activity budget. activity approval. Therefore, it should
disbursement for the investment? be reported separately from the
The disbursement is the actual size of the investment made committed amount.
by the DFI.

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 INDICATOR SURVEY QUESTION DEFINITION ADDITIONAL
DEFINITIONS AND NOTES

Does the DFI disclose the source of A statement on the origin of the funds for the investment. For
funding for the investment? example, a DFI may state that a project is funded by its own
resources or other funds that it manages such as donor trust funds.
13. Funding source
Where there is more than one source of funding amounts per
source is required.

Does the DFI disclose the name of the The name of the client company receiving investment. This could For sovereign operations the name of
client? include the name of the implementing agency or sponsor. the implementing agency should be
disclosed.
14. Client Does the DFI disclose a description of A narrative description of the client company receiving
the client? investment. This could include the description of the The description of the client needs to
implementing agency or sponsor. contain a minimum of 80 characters in
order to be considered a description.

Does the DFI disclose a relevant DFI A DFI contact shows who can be contacted in relation to For sovereign operations contact
contact? this activity at the DFI. This does not have to be the contact information for the implementing
information for an individual or project manager and could agency should be disclosed in the
Does the DFI disclose a relevant client refer to a central contact or information desk. same manner as described here.
contact?
A client contact shows who can be contacted in relation to
15. Contacts this activity at the client. This does not have to be the contact
information for an individual or project manager and could
refer to a central contact or information desk.

These must be stated alongside the activity or on an obvious

“contact us” link alongside the activity.

Does the DFI disclose the The E&S risk rating of an investment or project provides an
environmental and social (E&S) risk indication of the level of E&S risk associated with it. E&S risk
16. E&S risk category category of the activity? categories are typically reported by either letter (e.g. A to C) or
number (e.g. 1 to 3).

Does the DFI disclose the following Disclosed date: the date at which basic project information Both month and year are required to
dates: has been disclosed to the public. score on this indicator in recognition of
recipient countries needing to be able
• Disclosed date? Approval date: the date at which an investment or project is to map activities to their own financial
17. Progress dates • Approval date? approved by the DFI board. year rather than the calendar year.
• Last update date?
Last update date: the date at which basic project information
for a given investment or project was updated publicly.

Does the DFI disclose the investment Contract: the investment contract signed by the DFI and the
18. Contract (sovereign only) contract for the activity? client/borrower.

7
 INDICATOR SURVEY QUESTION DEFINITION ADDITIONAL
DEFINITIONS AND NOTES

IMPACT MANAGEMENT

ORGANISATIONAL LEVEL INDICATORS

Does the DFI publish a methodology An impact measurement approach should be either a
explaining its approach to impact standalone document or a dedicated section of the DFI
measurement? website.

Does the DFI indicate which standards/ The measurement approach should identify any alignment
initiatives it is aligned to? to recognised impact management standards (e.g. IRIS+ or
Harmonised Indicators for Private Sector Operations) as well
Does the DFI explain its approach to as the institution’s approach to determining additionality in
determining additionality? its activities.

Does the DFI explain its approach to Development additionality addresses the non-financial
determining impact attribution? aspects of a private sector DFI investment that would not be
provided by the private sector. This may include things such
19. Impact measurement Does the DFI have a policy on as provision of technical or governance advice as part of an
evaluation of investments?
approach investment.

Financial additionality refers to the finance that would

otherwise not be provided (or leveraged) by the private sector
due to real or perceived risks. This may be expressed through
terms (such as loan tenor) not offered by the market.

Impact attribution is the relationship between the amount of

finance provided and the impacts.

An evaluation policy outlines the DFIs approach to

conducting evaluations, the level at which evaluations will
occur (e.g. sector, region, country), and the factors that
determine whether or not an investment will be evaluated.

Does the DFI publish sector or (multi-) A sector strategy outlines the approach an institution takes If the organisation follows the strategy
country strategies? to investing in particular sectors. This may take the form of of a parent or related organisation, a
sectoral theories of change. statement clarifying this is needed on
the website along with a link to the
A (multi-)country strategy paper sets out the organisation’s relevant strategy document. Similarly,
20. Sector / country strategy planned approach and activities in the recipient country, if the organisation supports a country-
group of countries or region. For it to be accepted it needs to led or developed strategy, this must be
be a detailed document rather than just a paragraph on the explicitly stated on the website and the
organisation’s website. link to the relevant strategy document
needs to be provided.

8
 INDICATOR SURVEY QUESTION DEFINITION ADDITIONAL
DEFINITIONS AND NOTES

PROJECT LEVEL INDICATORS

Does the DFI identify the development Development additionality addresses the non-financial Recognising ongoing difficulties with
additionality of its investment? aspects of a private sector DFI investment that would not be measuring and proving additionality
provided by the private sector. This may include things such narrative statements will be accepted.
21. Additionality statement Does the DFI identify the financial as provision of technical or governance advice as part of an
(non-sovereign only) additionality of its investment? investment.

Financial additionality refers to the finance that would

otherwise not be provided (or leveraged) by the private sector
due to real or perceived risks. This may be expressed through
terms (such as loan tenor) not offered by the market.

Does the DFI disclose results indicators Project indicators are the key development outcomes that a Disclosed indicators that are defined at
for the activity? project is expected to achieve. an institutional level will be accepted.
22. Activity
Does the DFI disclose metrics, Metrics are the units of measurement within the indicators.
indicators / metrics definitions and methodologies for the
indicators? Definitions and methodologies clarify the use and collection
of indicators and metrics specific to the context of the activity.

Does the DFI disclose baseline data for The baseline value for the indicator is the value of the If the activity has ended, then the
identified indicators? indicator at the point that an activity commences. actual results should be available
within 12-months of ending.
Does the DFI disclose a target value for A target value is the intended final value of an indicator.
23. Results the indicators?
A record of the achieved result for this period is the current
Does the DFI disclose an actual/current value for the indicator for the most recent reporting period.
value for the indicators?

Does the DFI disclose whether an Evaluation and review documents consider, for example, what Not all organisations carry out formal
evaluation been completed for the the activity achieved, whether the intended objectives were evaluations for all their activities. In
activity? met, what the major factors influencing the achievement or cases where an evaluation has not
non-achievement of the objectives were and an assessment occurred this should be clearly stated.
If so, does the DFI disclose the of the impact, effect and value of the activity. This information
24. Evaluation evaluation? may be on a specific evaluation section of the organisation’s
website.

If the activity under assessment is not completed but interim

evaluation or review documents are available, these will be
accepted.

9
 INDICATOR SURVEY QUESTION DEFINITION ADDITIONAL
DEFINITIONS AND NOTES

ESG AND ACCOUNTABILITY TO COMMUNITIES

ORGANISATIONAL LEVEL INDICATORS

Does the DFI have a policy on early Global online E&S disclosure policy may be included in other If a DFI uses E&S standards other than
disclosure of investments? documentation including E&S standards or institutional its own, it should provide a link to the
disclosure policies. relevant documentation.
Does the DFI clearly articulate what
E&S documentation will be disclosed An early disclosure policy details the period of time that a DFI For DFIs that don’t apply risk
for medium and high-risk projects? has to disclose a proposed investment or activity before it is categorisation for projects the DFI
considered for board approval. should articulate what E&S documents
Does the DFI disclose the E&S will be disclosed for different projects.
policies/standards it applies (e.g. IFC The DFI should identify the minimum level of document
Performance Standards or in-house disclosure expected for medium and high risk (category B
policies) for its investments? and category A or equivalent) activities.

Does the DFI have a policy that E&S policies/standards govern the DFI’s management of E&S
25. E&S global specifies when a document should be risk. Examples include the IFC Performance Standards and
disclosure policy translated and in which language? EBRD Performance Requirements.

Does the DFI disclose an explanation of E&S documentation should be in relevant languages so that
project risk categorisation? it is accessible for stakeholders, especially project-affected
communities. DFI policy should set forth when and how
Does the DFI disclose a list of translation should happen, including when translation to the
investment exemptions? national language is required.

An explanation of project risk categorisation explains what

attributes of a project contribute to the application of risk
categories.

Investment exemptions are types of businesses (or sectors) in

which the DFI is prohibited from investing.

Does the DFI have a community A community E&S disclosure policy should establish the A project-affected person is a person or
disclosure policy? roles and responsibilities of the DFI and its client. It may be household affected by direct economic
included as an aspect of other documentation including E&S and social impacts caused by a project.
Does the policy require early disclosure standards or institutional disclosure policies.
to project-affected people?
An early disclosure policy details the period of time that a DFI
Does the DFI clearly articulate what has to disclose a proposed investment or activity to project-
26. E&S community E&S documentation will be disclosed affected people before it is considered for board approval.
disclosure policy to project-affected people for
investments? The DFI should identify the minimum level of document
disclosure to project-affected people for its activities.
Does the DFI have a free, prior, and
informed consent (FPIC) policy? An FPIC policy outlines the way a DFI achieves participation
and consultation in instances where its investment activities
involve indigenous peoples.

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 INDICATOR SURVEY QUESTION DEFINITION ADDITIONAL
DEFINITIONS AND NOTES

Does the DFI disclose the availability Global online IAM disclosure policy may be included as an
of the Independent Accountability aspect of other documentation including E&S standards or
Mechanism (IAM) on its website? institutional disclosure policies.
27. IAM global disclosure
documentation Does the DFI IAM have a publicly A publicly available registry should record all cases, results,
available registry that publishes results, responses, and findings of the IAM. The DFI should provide a
responses, or findings? link to the public registry if not located on its website.

Does the DFI require clients to disclose Community IAM disclosure policy may be included as an A project-affected person is a person or
the availability of the IAM to project- aspect of other documentation including E&S standards or household affected by direct economic
affected people where appropriate? institutional disclosure policies. and social impacts caused by a project.
28. IAM community
Or The DFI should define the role and responsibilities between
disclosure policy itself and its client for the disclosure of the availability of an
Does the DFI state that it will disclose IAM.
the availability of IAM to project-
affected people?

Does the DFI require clients to Community PGM disclosure policy may be included as an A project-affected person is a person or
disclose the availability of the project- aspect of other documentation including E&S standards or household affected by direct economic
level grievance mechanism (PGM) institutional disclosure policies. and social impacts caused by a project.
to project-affected people where
appropriate? The DFI should define the role and responsibilities between
29. PGM community
itself and its client for the disclosure of the availability of a PGM.
disclosure policy Or

Does the DFI state that it will disclose

the availability of the PGM to project-
affected people?

PROJECT LEVEL INDICATORS

Does the DFI disclose a summary of A summary of E&S risks may take the form of either a non- For non-sovereign projects the project
E&S risks for an activity? technical summary or a narrative description of the E&S title may be given as the client’s name.
aspects of an activity.
30. Summary of E&S risks Are E&S standards triggered by the The project ID must be stated clearly
project identified? E&S standards govern the DFI’s management of E&S risk. on the page. It is not sufficient if it
Examples include the IFC Performance Standards and EBRD is only stated in the URL. It must be
Performance Requirements. numeric or alpha-numeric.

Does the DFI disclose what E&S The DFI should list all E&S documents that were produced for
documentation was produced for the an activity, in line with institutional and national guidelines.
activity?
At a minimum, either an Environmental and Social Impact
31. E&S project
Does the DFI disclose all produced E&S Assessment (ESIA), a summary Environmental and Social
plans / assessments documents for the activity? Management System (ESMS), or a summary of the key E&S
risks, impacts and mitigation should be disclosed.

All produced E&S documents should be disclosed.

11
 INDICATOR SURVEY QUESTION DEFINITION ADDITIONAL
DEFINITIONS AND NOTES

Does the DFI state if disclosure of the Assurance of community disclosure is defined as the DFI Assurance of community disclosure
activity to projected-affected people stating the date, place, method, and content of community may be located in supplementary E&S
was required? disclosure of the funded activity. Community disclosure documentation such as a stakeholder
may be completed by the DFI, the client (or implementing engagement plan (SEP).
If yes, then: partner), or by an identified independent third party.

Does the DFI state the date of

community E&S disclosure?

32. Assurance of E&S Does the DFI state the place of

community disclosure community E&S disclosure?

Does the DFI state the method of

community disclosure?

Does the DFI state what

documentation was disclosed?

Does the DFI identify the language of

disclosure to project-affected people?

Does the DFI identify the main The identity of the shareholders holding above 10% of total Beneficial ownership statements at the
33. Beneficial ownership shareholders of the client company? shares of client companies should be disclosed. time of investment are accepted.
(non-sovereign only) Does the DFI disclose a beneficial A statement regarding the ultimate beneficial ownership of
ownership statement? client companies should be disclosed. An ultimate beneficial
owner is the person that is the ultimate beneficiary when an
institution initiates a transaction.

Does the DFI disclose the presence of The presence of an IAM should be disclosed on the project
34. IAM global disclosure the IAM on the DFI project page? page of each activity.

Does the DFI state if disclosure of Assurance of community disclosure is defined as the DFI
the presence of an IAM to projected- stating the date, place, method, and content of community
affected people is required? disclosure of an IAM. Community disclosure may be
completed by the DFI, the client (or implementing partner),
If yes, then: or by an identified independent third party.

Does the DFI state the date of

disclosure of the presence of an IAM to
project-affected people?
35. Assurance of IAM Does the DFI state the place of
community disclosure disclosure of the presence of an IAM to
project-affected people?

Does the DFI state the method of

disclosure of the presence of an IAM to
project-affected people?

Does the DFI state the language of

disclosure of the presence of an IAM to
project-affected people?
12
 INDICATOR SURVEY QUESTION DEFINITION ADDITIONAL
DEFINITIONS AND NOTES

Does the DFI state if disclosure of the Assurance of community disclosure is defined as the DFI
presence of a project-level grievance stating the date, place, method, and content of community
mechanism (PGM) to projected- disclosure of a project-level grievance mechanism.
affected people is required? Community disclosure may be completed by the DFI,
the client (or implementing partner), or by an identified
If yes, then: independent third party.

Does the DFI state the date of

disclosure of the presence of a PGM to
project-affected people?
36. Assurance of PGM
community disclosure Does the DFI state the place of
disclosure of the presence of a PGM to
project-affected people?

Does the DFI state the method of

disclosure of the presence of a PGM to
project-affected people?

Does the DFI state the language of

disclosure of the presence of a PGM to
project-affected people?

13
 INDICATOR SURVEY QUESTION DEFINITION ADDITIONAL
DEFINITIONS AND NOTES

FINANCIAL INFORMATION

ORGANISATIONAL LEVEL INDICATORS

Does the DFI disclose audited financial The organisation’s annual audit of its activities is an official A formally approved audit of annual
reports/statements? inspection of the accounts and activities of this organisation, accounts is required to score on this
typically by an independent body. indicator.

Audits up to date with regular audit cycles are accepted, i.e. Audits conducted by official
37. Financial if the organisation publishes biennial audits, the most recent government agencies such as State
reports / statements document within this time frame is accepted. Audit Offices or Controller General
Reports are accepted for this indicator.

Integrated reports that combine

annual reporting and financial
reporting are accepted for this field.

PROJECT LEVEL INDICATORS

Does the DFI disclose whether an Whether or not the DFI has made a prior investment with the A yes/no answer would be sufficient.
38. Repeat investment investment is a repeat investment? same client. This is inclusive of new and additional projects Ideally, in the case of yes, a link to prior
with the same client. investments would be provided.

Does the DFI disclose the currency that The currency that the investment is made in. This information should be disclosed
39. Currency of investment the investment is made in? explicitly and easily identifiable from e.g.
total project cost or commitment amount.

Does the investment have co-financers Co-financers are other investors involved in financing an
or guarantors? activity as part of syndication or a package offered to the
client as an integrated/coordinated financial solution.
If yes, then: Previous or future investors are not included.
40. Co-financing Does the DFI disclose the identity of Identification of co-financers should include the full client
the co-financers? name of involved parties.

Does the DFI disclose the amount of The amount of finance provided by each co-financer.
financing provided by each co-financer?

Does the DFI disclose how much Concessional finance may be grant elements of an element or
of the DFI investment amount was subsidies attached to an investment managed or provided by the
41. Concessionality concessional? DFI. The total amount of concessional finance should be disclosed.
(non-sovereign only) Does the DFI disclose why concessional A statement regarding the reason concessional finance was
finance was necessary? necessary for a given investment may be given in narrative form.

In cases of no concessionality, this data field should be

reported as 0 (zero).
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 INDICATOR SURVEY QUESTION DEFINITION ADDITIONAL
DEFINITIONS AND NOTES

Does the DFI disclose how much The amount of private finance that is mobilised by an
private finance was mobilised? investment. Mobilisation may be reported according to either
Organisation for Economic Co-operation and Development
Does the DFI disclose how much DFI (OECD) or Multilateral Development Bank (MDB)
finance was mobilised? methodologies. In either case, the reporting methodology
42. Mobilisation should be identified.
(non-sovereign only)
The amount of DFI finance that is mobilised by an
investment. Mobilisation may be reported according to either
OECD or MDB methodologies. In either case, the reporting
methodology should be identified.

In cases of no mobilisation, this data field should be reported

as 0 (zero).

Equity Share of equity: the share of a company purchased by an

equity investment.
Share of equity: does the DFI disclose
what percentage of the client
company was purchased through the
investment?

Debt Interest rate: the interest rate applied to a loan investment.

Interest rate: does the DFI disclose Loan tenor: the repayment duration of a loan investment.
43. Instrument-specific
what interest rate was charged for the
disclosure loan?

Loan tenor: does the DFI disclose what

the length of the loan is?

Guarantees Length of guarantee: the length of time a guarantee/

insurance is valid for.
Length of guarantee: does the DFI
disclose what the length of the
guarantee is?

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 INDICATOR SURVEY QUESTION DEFINITION ADDITIONAL
DEFINITIONS AND NOTES

FINANCIAL INTERMEDIARY SUB-INVESTMENT DISCLOSURE

Does the DFI disclose the number Sub-investments made through banks qualify for disclosure if
of sub-investments that qualify for the DFI is materially exposed to them and they are:
disclosure?
a) High risk (category A or equivalent), or
44. Number of qualifying b) Larger than thresholds set out in the Equator Principles
sub-investments (version 4).

All sub-investments made through funds (such as, venture

capital funds, private equity funds, and debt funds) qualify for
disclosure.

Does the DFI disclose the name of the The name of the sub-investment company receiving In some jurisdictions disclosure of this
sub-investee? investment from the financial intermediary. data field is reliant on consent from the
sub-investee. In cases where consent
45. Sub-investee name is not granted this should be stated
explicitly with reference to the relevant
legislation that prevents disclosure.

Does the DFI disclose the country of The country or countries of operation that the investment will In some jurisdictions disclosure of this
the sub-investee? be utilised in. data field is reliant on consent from the
sub-investee. In cases where consent
46. Country is not granted this should be stated
explicitly with reference to the relevant
legislation that prevents disclosure.

Does the DFI disclose the sector of the The sectors of the activity explain whether this is, for example, In some jurisdictions disclosure of this
sub-investee? a health or education project. It does not count if it is just data field is reliant on consent from the
mentioned incidentally within the title or description. It needs sub-investee. In cases where consent
47. Sector to be stated separately and explicitly. is not granted this should be stated
explicitly with reference to the relevant
legislation that prevents disclosure.

Does the DFI disclose a description of A narrative description of the sub-investee. In some jurisdictions disclosure of this
the sub-investee? data field is reliant on consent from the
sub-investee. In cases where consent
is not granted this should be stated
explicitly with reference to the relevant
48. Sub-investee description legislation that prevents disclosure.

The description of the sub-investee

needs to contain a minimum of 80
characters in order to be considered a
description.

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 INDICATOR SURVEY QUESTION DEFINITION ADDITIONAL
DEFINITIONS AND NOTES

Does the DFI disclose the E&S risk The E&S risk rating of a sub-investment or project provides an In some jurisdictions disclosure of this
category of the sub-investment? indication of the level of E&S risk associated with it. E&S risk data field is reliant on consent from the
categories are typically reported by either letter (e.g. A to C) or sub-investee. In cases where consent
49. E&S risk categorisation number (e.g. 1 to 3). is not granted this should be stated
explicitly with reference to the relevant
legislation that prevents disclosure.

Does the DFI disclose the start date of The date at which an investment or project begins operation, In some jurisdictions disclosure of this
the sub-investment? or funds are dispersed. data field is reliant on consent from the
sub-investee. In cases where consent
is not granted this should be stated
explicitly with reference to the relevant
legislation that prevents disclosure.
50. Start date
Both month and year are required to
score on this indicator in recognition of
recipient countries needing to be able
to map activities to their own financial
year rather than the calendar year.

Does the DFI disclose the end date of The date at which the investment or project ends for the In some jurisdictions disclosure of this
the sub-investment? financial intermediary. This could include project completion data field is reliant on consent from the
dates, debt repayment dates, or equity exits. sub-investee. In cases where consent
is not granted this should be stated
explicitly with reference to the relevant
legislation that prevents disclosure.
51. End date
Both month and year are required to
score on this indicator in recognition of
recipient countries needing to be able
to map activities to their own financial
year rather than the calendar year.

Does the DFI disclose a relevant sun- This shows who can be contacted in relation to this activity In some jurisdictions disclosure of this
investee contact? at the sub-investee. This does not have to be the contact data field is reliant on consent from the
information for an individual or project manager and could sub-investee. In cases where consent
52. Sub-investee contact refer to a central contact or information desk. is not granted this should be stated
explicitly with reference to the relevant
legislation that prevents disclosure.

17